On July 01, 2021 a
Answer
was filed
involving a dispute between
Porter, Tiffany,
and
Cardinal Transport, Inc.,
Martinez, Richard,
for MOTOR VEHICLE ACCIDENT
in the District Court of Dallas County.
Preview
DISTRICT GEE-
7/26/2021 9:28 AM
FELICIA PITRE
DALLAS CO., TEXAS
CAUSE N0. DC-21-08568
MartinReyes DEPUTY
TIFFANY PORTER § IN THE DISTRICT COURT
Plaintiff, §
§
V. § DALLAS COUNTY, TEXAS
§
CARDINAL TRANSPORT, INC. AND §
RICHARD MARTINEZ §
Defendants. § 193R” JUDICIAL DISTRICT
DEFENDANT CARDINAL TRANSPORT, INC.’S ORIGINAL
ANSWER TO PLAINTIFF’S ORIGINAL PETITION
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Cardinal Transport, Inc., Defendant herein, and file this its Original
Answer to Plaintiff’ s Original Petition, and in support thereof would respectfully show unto this
Honorable Court as follows:
I.
GENERAL DENIAL
Defendant denies each and every, all and singular, the allegations contained in Plaintiff’s
Original Petition and demands strict proof thereof as authorized by Texas Rule of Civil Procedure
92.
II.
INITIAL DISCLOSURE
Under Texas Rule of Procedure 194.2, Defendant requests that Plaintiff makes her initial
disclosures, within thirty (30) days of the filing of Defendant’s Original Answer, and provide
information or material described in Rule 194.2(b) of the Texas Rules of Civil Procedure.
DEFENDANT CARDINAL TRANSPORT, INC.’S ORIGINAL
ANSWER TO PLAINTIFF’S ORIGINAL PETITION Page 1
IV.
NOTICE OF INTENT TO USE DOCUMENTS PRODUCED
PURSUANT TO RULE 193.7
Defendant places Plaintiff on notice that pursuant to Texas Rule of Civil Procedure 193.7,
all documents produced by Plaintiff in this litigation are authenticated for use against the producing
party in this case and may be used as evidence during pre-trial procedures and at trial of this matter.
V.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Defendant prays that upon final hearing
hereof, Plaintiff take nothing by way of her cause of action herein, that Defendant recover its costs
herein expended, and for such other and further relief, at law or in equity, to which Defendant may
show itself justly entitled to receive.
Respectfully submitted,
SARGENT LAW, P.C.
By: /s/ David Sargent
DAVID L. SARGENT
State Bar No.: 17648700
david.sargent@sargentlawtx.com
Martha M. Posey
State Bar No. 24105946
martha.posev@sargentlawtxcom
1717 Main Street, Suite 4750
Dallas, Texas 75201
Telephone: (214) 749-6000
Facsimile: (214) 749-6100
ATTORNEYS FOR DEFENDANT
CARDINAL TRANSPORT, INC.
DEFENDANT CARDINAL TRANSPORT, INC.’S ORIGINAL
ANSWER TO PLAINTIFF’S ORIGINAL PETITION Page 2
CERTIFICATE OF SERVICE
The undersigned certifies that on the 26th day of July 2021, a true and correct copy of the
foregoing document was forwarded Via E-File to Plaintiff’s counsel of record:
Colby Lewis
LAW OFFICES 0F COLBY LEWIS
405 Main Street
Houston, Texas 77002
colby@clewislaw.com
W. Clark Martin IV
THE MARTIN LAW FIRM, PLLC
3501 Allen Parkway
Houston, Texas 77019
w.martin@waltennartinlaw.com
/s/ David L. Sargent
DAVID L. SARGENT
2115157 v.1
9000/0000]
DEFENDANT CARDINAL TRANSPORT, INC.’S ORIGINAL
ANSWER TO PLAINTIFF’S ORIGINAL PETITION Page 3
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
David Sargent on behalf of Martha Posey
Bar No. 24105946
david.sargent@sargentlawtx.com
Envelope ID: 55679265
Status as of 7/26/2021 2:33 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
COLBY LEWIS Colby@CLewisLaW.com 7/26/2021 9:28:39 AM SENT
Nancy Blum nancy.blum@sargentlawtx.com 7/26/2021 9:28:39 AM SENT
Debbie Yeager debbie.yeager@sargentlawtx.com 7/26/2021 9:28:39 AM SENT
Walter Martin 24076535 w.martin@waltermartinlaw.com 7/26/2021 9:28:39 AM SENT
Associated Case Party: CARDINAL TRANSPORT, INC.
Name BarNumber Email TimestampSubmitted Status
Martha Posey martha.posey@sargentlawtx.com 7/26/2021 9:28:39 AM SENT
David LSargent david.sargent@sargentlawtx.com 7/26/2021 9:28:39 AM SENT
Document Filed Date
July 26, 2021
Case Filing Date
July 01, 2021
Category
MOTOR VEHICLE ACCIDENT
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DISTRICT GEE- 7/26/2021 9:28 AM FELICIA PITRE DALLAS CO., TEXAS CAUSE N0. DC-21-08568 MartinReyes DEPUTY TIFFANY PORTER § IN THE DISTRICT COURT Plaintiff, § § V. § DALLAS COUNTY, TEXAS § CARDINAL TRANSPORT, INC. AND § RICHARD MARTINEZ § Defendants. § 193R” JUDICIAL DISTRICT DEFENDANT CARDINAL TRANSPORT, INC.’S ORIGINAL ANSWER TO PLAINTIFF’S ORIGINAL PETITION TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Cardinal Transport, Inc., Defendant herein, and file this its Original Answer to Plaintiff’ s Original Petition, and in support thereof would respectfully show unto this Honorable Court as follows: I. GENERAL DENIAL Defendant denies each and every, all and singular, the allegations contained in Plaintiff’s Original Petition and demands strict proof thereof as authorized by Texas Rule of Civil Procedure 92. II. INITIAL DISCLOSURE Under Texas Rule of Procedure 194.2, Defendant requests that Plaintiff makes her initial disclosures, within thirty (30) days of the filing of Defendant’s Original Answer, and provide information or material described in Rule 194.2(b) of the Texas Rules of Civil Procedure. DEFENDANT CARDINAL TRANSPORT, INC.’S ORIGINAL ANSWER TO PLAINTIFF’S ORIGINAL PETITION Page 1 IV. NOTICE OF INTENT TO USE DOCUMENTS PRODUCED PURSUANT TO RULE 193.7 Defendant places Plaintiff on notice that pursuant to Texas Rule of Civil Procedure 193.7, all documents produced by Plaintiff in this litigation are authenticated for use against the producing party in this case and may be used as evidence during pre-trial procedures and at trial of this matter. V. PRAYER WHEREFORE, PREMISES CONSIDERED, Defendant prays that upon final hearing hereof, Plaintiff take nothing by way of her cause of action herein, that Defendant recover its costs herein expended, and for such other and further relief, at law or in equity, to which Defendant may show itself justly entitled to receive. Respectfully submitted, SARGENT LAW, P.C. By: /s/ David Sargent DAVID L. SARGENT State Bar No.: 17648700 david.sargent@sargentlawtx.com Martha M. Posey State Bar No. 24105946 martha.posev@sargentlawtxcom 1717 Main Street, Suite 4750 Dallas, Texas 75201 Telephone: (214) 749-6000 Facsimile: (214) 749-6100 ATTORNEYS FOR DEFENDANT CARDINAL TRANSPORT, INC. DEFENDANT CARDINAL TRANSPORT, INC.’S ORIGINAL ANSWER TO PLAINTIFF’S ORIGINAL PETITION Page 2 CERTIFICATE OF SERVICE The undersigned certifies that on the 26th day of July 2021, a true and correct copy of the foregoing document was forwarded Via E-File to Plaintiff’s counsel of record: Colby Lewis LAW OFFICES 0F COLBY LEWIS 405 Main Street Houston, Texas 77002 colby@clewislaw.com W. Clark Martin IV THE MARTIN LAW FIRM, PLLC 3501 Allen Parkway Houston, Texas 77019 w.martin@waltennartinlaw.com /s/ David L. Sargent DAVID L. SARGENT 2115157 v.1 9000/0000] DEFENDANT CARDINAL TRANSPORT, INC.’S ORIGINAL ANSWER TO PLAINTIFF’S ORIGINAL PETITION Page 3 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. David Sargent on behalf of Martha Posey Bar No. 24105946 david.sargent@sargentlawtx.com Envelope ID: 55679265 Status as of 7/26/2021 2:33 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status COLBY LEWIS Colby@CLewisLaW.com 7/26/2021 9:28:39 AM SENT Nancy Blum nancy.blum@sargentlawtx.com 7/26/2021 9:28:39 AM SENT Debbie Yeager debbie.yeager@sargentlawtx.com 7/26/2021 9:28:39 AM SENT Walter Martin 24076535 w.martin@waltermartinlaw.com 7/26/2021 9:28:39 AM SENT Associated Case Party: CARDINAL TRANSPORT, INC. Name BarNumber Email TimestampSubmitted Status Martha Posey martha.posey@sargentlawtx.com 7/26/2021 9:28:39 AM SENT David LSargent david.sargent@sargentlawtx.com 7/26/2021 9:28:39 AM SENT